From Kitchen Table to Courtroom: Lessons from the Federal Circuit’s Ruling on AI Patent Eligibility

In a landmark decision on April 18, 2025, the U.S. Court of Appeals for the Federal Circuit addressed the patent eligibility of artificial intelligence (AI) inventions under 35 U.S.C. § 101 in the case of Recentive Analytics, Inc. v. Fox Corp. This ruling has significant implications for AI innovators, patent practitioners, and businesses navigating the complex landscape of intellectual property rights in the realm of machine learning and AI technologies.

Case Overview: Recentive Analytics v. Fox Corp.

Recentive Analytics, Inc. filed a lawsuit against Fox Corporation, alleging infringement of four patents related to the use of machine learning for generating network maps and schedules for television broadcasts and live events. The patents in question included U.S. Patent Nos. 10,911,811, 10,958,957, 11,386,367, and 11,537,960. The district court dismissed the case, concluding that the patents were directed to ineligible subject matter under § 101. The Federal Circuit affirmed this decision, emphasizing that the patents merely applied generic machine learning techniques to the fields of event scheduling and network map creation, and thus were directed to abstract ideas lacking an inventive concept sufficient to satisfy the requirements of § 101. (Bracewell LLP)

Understanding the Federal Circuit’s Decision

The court applied the two-step framework established in Alice Corp. v. CLS Bank International to assess patent eligibility:

Determine whether the claims are directed to a patent-ineligible concept, such as an abstract idea.

At step one, the Federal Circuit found that the claims were directed to abstract ideas—producing event schedules and network maps using known mathematical techniques.

At step two, the court concluded that the claims lacked an inventive concept, as they merely applied generic machine learning techniques and relied on conventional computing devices.

Key Takeaways for AI Innovators and Patent Practitioners

The ruling provides several critical insights:

AI Patent Eligibility: Standard AI application to existing problems may not meet patent criteria. Field-of-use limits are insufficient. Detail how AI improves methods, model, data & enhancements. Align with USPTO for computer functionality improvements.

Strategies for Strengthening AI Patent Applications

To enhance the likelihood of obtaining patent protection for AI inventions:

Focus on Technical Improvements: Clearly define how the AI invention improves the functioning of a computer or another technology.

Provide Specific Implementation Details: Include detailed information about the AI model’s architecture, training process, data inputs, and outputs.

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